PSEG filed a Protest of PJM's compliance filing for their new planning process at FERC today. I had to read it several times... and I'm still not sure what they're up to here, but at face value it makes them look like Sybil. Overall, it's kind of like a pair of new shoes that rubs the wrong way, but you can't quite figure out what's causing the irritation.
First PSEG complains about PJM's new planning scenarios allowing decisions to be made within the mysterious "black box." We've been complaining about PJM's mysterious "black box" for years, but because the old black box worked for PSEG, that was okay. However, if PJM would now make black box decisions that include public policy considerations, that's not transparent enough for PSEG.
"The vague criteria of “the PJM’s engineering expertise and experience as the transmission planner and operator for the PJM region” does not provide sufficient clarity
regarding the decisional framework. PJM’s proposal is tantamount to black box decisionmaking. It fails to provide any decisional criteria that PJM would be obligated to follow in finalizing the RTEP before sending it to the Board for approval. It says nothing about how PJM will pick one scenario over another or whether such scenarios will be weighted based on any factors. As such, the issue of how PJM will be utilizing scenario planning in making RTEP decisions stands no clearer post compliance filing than before."
Next PSEG goes completely Sybil and complains that PJM puts no limits on how much an existing project could be modified and that such a modified project may no longer comply with market efficiency cost controls. Yeah, I know... how can they say this with a straight face while simultaneously pushing their Susquehanna-Roseland white elephant??
"Further, the compliance filing puts no bounds on the extent to which an existing reliability or market efficiency project may be modified as a result of the sensitivity and scenario studies. Such an open-ended option puts at risk the cost control measures that
currently ensure that customers do not pay for projects that are neither economic nor “gold-plated” from a reliability standpoint. For example, under current rules, a market efficiency project must pass a cost benefit test in order to be included in the RTEP. Scenario planning may point to further project enhancements, but the compliance filing sets forth no requirement that such enhancements must also pass the same cost benefit
test. Without such a requirement, the fundamental cost controls that ensure customers do not pay for uneconomic transmission upgrades would be lost."
PSEG puts the caboose on their crazy train by insisting that PJM align their RTEP assumptions with their RPM results. PSEG (and PJM though the quote PSEG cited) insist that the RPM is working and responded perfectly to generation retirements, although the Market Monitor has been on the warpath about the new generation that cleared, saying that it skewed the market. Now they're all fighting over who gets to wear the straight jacket! PSEG says that "public policy" scenario assumptions that have not cleared the RPM should not be considered. Okay... so let's apply that to S-R, shall we? How about we retool that loser using the latest RPM results?
Is PSEG looking to dump their "gold plated reliability project" at this point in time? C'mon PJM, step up here and be the hero. Kill it, kill it, kill it!
Meanwhile, Atlantic Wind Connection made a filing complaining that PJM didn't include public policy scenario criteria in its compliance filing. I guess they think they're about to be left at the alter...
I wonder if the FERC Commissioners can just send everyone to their rooms without supper? Maybe some day we can make transmission decisions that are actually in the best interests of consumers, and not corporate bottom lines. Call me a dreamer.
First PSEG complains about PJM's new planning scenarios allowing decisions to be made within the mysterious "black box." We've been complaining about PJM's mysterious "black box" for years, but because the old black box worked for PSEG, that was okay. However, if PJM would now make black box decisions that include public policy considerations, that's not transparent enough for PSEG.
"The vague criteria of “the PJM’s engineering expertise and experience as the transmission planner and operator for the PJM region” does not provide sufficient clarity
regarding the decisional framework. PJM’s proposal is tantamount to black box decisionmaking. It fails to provide any decisional criteria that PJM would be obligated to follow in finalizing the RTEP before sending it to the Board for approval. It says nothing about how PJM will pick one scenario over another or whether such scenarios will be weighted based on any factors. As such, the issue of how PJM will be utilizing scenario planning in making RTEP decisions stands no clearer post compliance filing than before."
Next PSEG goes completely Sybil and complains that PJM puts no limits on how much an existing project could be modified and that such a modified project may no longer comply with market efficiency cost controls. Yeah, I know... how can they say this with a straight face while simultaneously pushing their Susquehanna-Roseland white elephant??
"Further, the compliance filing puts no bounds on the extent to which an existing reliability or market efficiency project may be modified as a result of the sensitivity and scenario studies. Such an open-ended option puts at risk the cost control measures that
currently ensure that customers do not pay for projects that are neither economic nor “gold-plated” from a reliability standpoint. For example, under current rules, a market efficiency project must pass a cost benefit test in order to be included in the RTEP. Scenario planning may point to further project enhancements, but the compliance filing sets forth no requirement that such enhancements must also pass the same cost benefit
test. Without such a requirement, the fundamental cost controls that ensure customers do not pay for uneconomic transmission upgrades would be lost."
PSEG puts the caboose on their crazy train by insisting that PJM align their RTEP assumptions with their RPM results. PSEG (and PJM though the quote PSEG cited) insist that the RPM is working and responded perfectly to generation retirements, although the Market Monitor has been on the warpath about the new generation that cleared, saying that it skewed the market. Now they're all fighting over who gets to wear the straight jacket! PSEG says that "public policy" scenario assumptions that have not cleared the RPM should not be considered. Okay... so let's apply that to S-R, shall we? How about we retool that loser using the latest RPM results?
Is PSEG looking to dump their "gold plated reliability project" at this point in time? C'mon PJM, step up here and be the hero. Kill it, kill it, kill it!
Meanwhile, Atlantic Wind Connection made a filing complaining that PJM didn't include public policy scenario criteria in its compliance filing. I guess they think they're about to be left at the alter...
I wonder if the FERC Commissioners can just send everyone to their rooms without supper? Maybe some day we can make transmission decisions that are actually in the best interests of consumers, and not corporate bottom lines. Call me a dreamer.
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